20031212Response of Farmers Mutual.pdf

FARMERS MUTUAL TELEPHONE COMPANY
319 S. W 3rd St. P.O. Box 1030 Fruitland, 1D 83619 . [phone] . Fax [phone]
RE: Response toCASE NO. GNR-03-
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December 11 , 2003
WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
Mr. Stutzman
Enclosed is the response by Farmers Mutual Telephone Company to the above referenced case. As we
discussed on the phone, the majority of my responses are N/ A due to the questions primarily addressing
unbundling service, which is not a possibility on a wireless switch. Please call me if you have any
questions, 208-452-4241.
Barbara A. Choate
PCS Supervisor
enclosure
WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
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UTILITiES C0I1!"ilSSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLICATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338).
NINE-MONTH REVIEW ON ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES.
CASE NO. GNR-03-
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO WIRELESS
COMP ANIES
This response is being completed by the following for all requests:
Barbara A. Choate
PCS Supervisor, Snake River PCS
Farmers Mutual Telephone Company
319 SW 3rd Street
O. Box 1030
Fruitland, Idaho 83619
208-452-4241
Mass Market Switching
Request No.1: Provide a list of all switches that you currently use to provide a qualifying
service (as defined in 47 c.F.R. 9 51.5 , as that section will be amended by the Final Rules issued by
the FCC pursuant to the Triennial Review Order) anywhere in the state, regardless of whether the
switch itself is located in the state. Do not include ILEC switches utilized by you on an unbundled
basis in the ILEC's service territory or through the resale of the incumbent's services at wholesale
rates.
Response No.1: Nortel MTX is the only wireless switch owned by Farmers Mutual Telephone Co.
Response to IPUC Cas(; No. BNR.
j'-
O3-23 by Farmers Mutua!l'd(;phone Company
Request No.2: Identify each ILEC wire center district (i.the territory served by a wire
center of the ILEC) in which you provide qualifying service to any end user customers utilizing any
of the switches identified in your response to Request No.1. Wire centers should be identified by
providing their name, address, and CLLI code.
Response No.2: The switch is physically located in the NuAcres wire center of Farmers Mutual
Telephone Company. Towers where service is provided to customers are located in Payette, Valley
and Washington Counties.
Request No.3: For each ILEC wire center identified in response to Request No., identify
the total number of voice-grade equivalent lines 1 you are providing to customers in that wire center
from your switch(es) identified in response to Request No. 1. For purposes of this request
, "
voice-
grade equivalent lines" should be defined consistent with the FCC's use of the term.
Response No.3: The switch has a total of 196 voice channels that are utilized by the customers of
the Snake River PCS network as well as roaming partners. There are no "lines" dedicated to any
specific wireless service user.
Request No.4: For each switch identified in response to Request No., identify the
approximate capacity of the switch - that is, the maximum number of voice-grade equivalent lines it
is capable of serving - based on that switch's existing configuration and component parts.
Response No.4: Each of the 7 towers owned by Farmers Mutual Telephone Company can carry a
maximum of22 callsper sector at any given time. Capacity issues are traffic based and time
dependent as facilities are not specifically assigned to a wireless handset by the system. Which
tower is being used and how many users are on the tower speaking continually are the variables
associated with capacity. The McCall tower could be blocking traffic while the Fruitland tower is
only serving one or two customers.
Request No.5: With respect to the voice-grade equivalent lines identified in response to
Request No., separately indicate the number being provided to (a) residential customers;
(b) business customers to whom you provide only voice-grade or DSO lines.
Response No.5: We do not gather information from our customers as to whether their wireless
phone is for business or personal use so this information is not available.
Request No.6: For each of the switches identified in your response to Request No., state
1 Voice.grade equivalent lines would include DSO lines and, by the defmition in FCC F onn 477 Instructions for the
Local Competition and Broadband Reporting From include traditional analog POTS lines, Centrex-CO extensions and
Centrex-CE trunks, Line counts are based on how they are charged to the customer rather than how they are physically
Response to ll)lTC Case No. BNR.O3-23 by Famlers Mutual Te1eprlOne Company
whether the switch is owned by you, or whether you have leased the switching capacity or otherwise
obtained the right to use the switch on some non-ownership basis. If the facility is not owned by
you, identify the entity owning the switch and (if different) the entity with which you entered into
the lease or other arrangement, identify the nature of the arrangement, and state whether such entity
or entities are affiliates of yours, in the sense defined in ~ 408, footnote 1263 of the Triennial
Review Order.
Response No.6: Farmers Mutual Telephone Company owns the Nortel MTX switch.
Request No.7: With respect to the voice-grade equivalent lines being provided to
(a) residential customers; (b) business customers to whom you provide between 1-3 voice-grade
equivalent lines at one location; (c) business customers to whom you provide between 4-24 voice
grade equivalent lines at one location; and (d) business customers to whom you provide 24 or more
voice-grade equivalent lines (in one location), state the current average total monthly revenues
earned per line served in the state by LATA and by MSA and specify the source of those revenues
by service type.
Response No.7: N/A
Request No.8: For each switch (e.g. circuit, packet, soft switch, etc.) currently used, or
those that have been used, or that could be used to provide local service in the state (this would
include switches located in other states that provide or have the ability to provide local exchange
service in the state), state the initial cost of that switch, including installation and engineering costs
and the number of initial equipped lines.
Response No.8: N/A
Request No.9: Describe in detail any instances in which your company is using, through a
wholesale, lease, or resale arrangement, the switch of any entity other than and unaffiliated with an
ILEC (e., another competitive local exchange carrier) to provide local exchange service to end
users in the state. Include in your response the rates, terms, and conditions under which you are
obtaining switching on a wholesale, lease, or resale basis.
Response No.9: N/A
Request No. 10: State whether your company is providing, or plans to provide, through a
Response to IPtJC Case No. BNR-O3-23 by Farmers Mutua! Te1ephonc Company
wholesale, lease or resale arrangement, capacity on any switches you own or operate in the state, or
that own or operate in another state and that you use to provide local service in the state, to an
unaffiliated entity. For any such instances, identify the rates, terms, and conditions under which you
are making that switch capacity available. For each switch on which you are currently leasing or
selling capacity to an unaffiliated entity, identify:
a. The make, model, age, and current software upgrades of each switch;
b. The geographic location of the switch;
c. The footprint or geographic area served by the switch, including a list of each
exchange served by the switch; the features and functions (including software
upgrades) available in the switch;
d. Provide the capacity of each switch, including:
(i) percentage of switch capacity in use;
(ii) percentage of switch capacity reserved for your company s own use and future
use; and
(iii) percentage of current and future capacity of each switch that will be made
available for CLEC use.
e. For each switch identified, please state in detail:
(i) the anticipated service life of the switch; and
(ii) whether your company intends to utilize the identified switch for the full
anticipated service life.
Response No. 10: N/A
Request No. 11: For each Qwest wire center in Idaho in which the CLEC provides retail
switched local exchange service, please report the number of switched voice-grade equivalent lines
in service per customer location that the CLEC serves. Please provide this information in the
following format: (total number oflines at locations with a single line at that location, number of
lines at locations with two lines at that location, etc.
WIRE CENTER:
QuantityofVGE
Response to TI)UC Case No. BNR-O3-23 by Farmers Mutual Tdephonc Company
per Customer Location
24 or more
Response No. 11: N/A
Residence Business
Request No. 12: For each switch the CLEC owns, operates, controls, maintains , or from
which you lease dial tone or trunking functionality/capacity within Idaho, please state whether the
local switching capacity of the switch can be expanded through modular software and hardware
additions. If you assert any obstacles to expansion, please identify and explain all such obstacles.
Response No. 12: N/A
Request No. 13: Does the CLEC believe that there are costs associated with converting or
otherwise using a switch currently serving only enterprise customers to also serve mass-market
customers? If the CLEC believes that there are such switching costs, please identify all such costs
and explain why it would be necessary to incur them to begin serving mass-market customers,
Produce any documents or data that support your response.
Response No. 13: N/A
Response to IPlTC Case No. BNR-O3-23 by Farmers Mutual Tdephone Company
Request No. 14: Please provide, a) on a statewide basis, and b) on a central office-specific
basis, monthly data for the past two years on customer "chum (i.percentage of your customers
lost to another carrier) on all of the following bases:
(a) number of customers by customer type (e.
g.,
residential, business with one to
three lines; business with more than three lines);
(b) percentage of chum by customer type (e.
g.,
residential, business with one to three
lines, business with more than three lines);
(c) number of customers by service type (i. , local exchange voice service only,
long distance voice service only, bundled local exchange and long distance voice
services, and bundled local exchange, long distance, and DSL services);
(d) percentage of chum by service type (i.local exchange voice service only,
long distance voice service only, bundled local exchange and long distance voice
services, and bundled local exchange, long distance, and DSL services).
Response No. 14: a-c chum rates are not calculated by customer type
d. Wireless service is not unbundled so service type is not applicable
Request No. 15: For customers that purchase up to 24 voice grade equivalent lines please
identify the types or categories of customer acquisition costs the CLEC incurred in Idaho in 2001
and 2002 to attract new customers, set up their accounts, and establish service to them. In addition
please provide the per line costs the CLEC incurred in 2001 and 2002 for both business and
residential customers for each of the types or categories of customer acquisition costs.
Response No. 15: N/A
Request No. 16: For customers that purchase up to 24 voice grade equivalent lines please
identify the monthly chum rate the CLEC has experienced for local exchange customers in each
month in which it has provided local exchange service in the Idaho market. In answering this
request, calculate the chum rate based upon the number of lines lost each year divided by the
average number of lines in service that year. In calculating chum, do not include customers who
move but stay with the company. Please produce all documents that refer or relate to the
information you provide in response to this request.
Response No. 16: N/A
Response to ll)lTC Case No, BNR-'r-O3-n by Farmers Mutua! Tdephonc Company
Request No. 17: Please identify the percentage of customers that have left within one
month of signing up for service, within two months of signing up for service, within three months of
signing up for service, and within six months of signing up for service. Please provide this
information in connection with the CLEC's chum rates in Idaho for the most recent 24 months that
are available for local exchange customers that purchase up to 24 voice grade equivalent lines.
Please produce all documents that refer or relate to the information you provide in response to this
request.
Response No. 17: This information is not available as chum rates are not calculated in this manner.
Request No. 18: For customers that purchase up to 24 voice grade equivalent lines please
identify each rate plan that the CLEC offers to local exchange customers in Idaho. In addition
please identify the percentage of the CLEC's total local exchange customers in Idaho that subscribe
to each plan that you identify. Please produce all documents that reflect, refer or relate to the
information you provide in response to this request.
Response No. 18: N/A
Request No. 19: For rate plans identified in B.B. that include a per minute of use
component, please provide the average long distance per minute usage in Idaho of the CLEC's local
exchange customers who subscribe to such plans for the most recent 24 months available. Please
produce all documents that reflect, refer, or relate to the information you provide in response to this
request.
Response No. 19: N/A
Request No. 20: For customers that purchase up to 24 voice grade equivalent lines how
many CLEC-to-CLEC cross-connects has the CLEC performed in Idaho since June 2001? How
many CLEC-to-CLEC cross-connects does the CLEC maintain in Idaho at present?
Response No. 20: N/A
The Development of an Efficient Loop Migration Process
Response to IFUC Case No. BNR.O3-23 by Farmers Mutual Te1ephone Company
Request No. 21: Describe the hot cut process currently used to transfer lines from the ILEC
switch to the CLEC facilities.
Response No. 21: N/A
Request No. 22: List each task that is part of the current process. Provide the average time
it takes to complete the task, the typical occurrence of the task during the process, the labor rate for
the task, and the common overhead loading associated with the labor rate. Indicate the source of the
data, i.e. time/motion studies, SME analysis , etc.
Response No. 22: N/A
Request No. 23: Describe a batch hot cut process that you would implement to meet the
FCC's requirement to establish a batch hot cut process. Include an estimate of the maximum
number of lines per batch.
Response No. 23: N/A
Request No. 24: List each task that is part of the batch hot cut process described in the
answer to the preceding request. Provide the average time it takes to complete the task, the typical
occurrence of the task during the process, the labor rate for the task, and the common overhead
loading associated with the labor rate.
Response No. 24: N/A
Request No. 25: IfUNE-P is no longer available, what monthly volumes of hot cuts would
be required: (a) to migrate existing UNE-P customers to another form of service and (b) to connect
new customers in the ordinary course of business. Provide supporting documentation for these
volume estimates.
Response No. 25: N/A
Submitted December 11 2003
Barbara A. Choate
Response to IPlJC Case No, BNR-O3-23 by Fanners Mutual 'Telephone Company